Comment Response Sheet Response Remarks ... engineering. Monitoring requirements for treated wastewater are presented in ... Comment Response Sheet

Comment Response Sheet (CRS)

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Project Title (ESIA) Tahrir Petrochemicals Complex, Economic Zone, Ain Sokhna, Egypt

Customer Tahrir Petrochemicals

Project No. EJ6195 CRS No. 01

Document Title Prepared By WorleyParsons Date 14.01.2015

Document No. Rev. No. 0 Sheet of

Except for the following identified comments, all other comments on this document have been resolved.

No. Section/ Page

Comment Response Remarks

1.1 Tahir Petrochemicals Complex Project Should meet the

following Environmental and Social Standards

a- The OECD council recommendations on common

Approaches on the environment and officially Support

Credit (July 2014)

b- The IFC Performance Standards (2012)

c- EHS guidelines for large volume Petroleum based

Organic Chemicals Manufacturing, Petroleum-based

Polymers Manufacturing, Thermal Power, Crude Oil

Petroleum Product Terminals, Water and Sanitation

Tahrir Petrochemicals Complex project compliance with the

following standards/guidelines will be demonstrated in the ESIA

Report as applicable:

a. Organization for Economic Co-operation and Development

(OECD) Recommendation of the council on common

approaches for officially supported export credits and

environmental and social due diligence, June 2012.

Should there is specific guidelines dated 2014 you are

kindly requested to provide us a copy of it.

b. The IFC Performance Standards (2012)

c. EHS guidelines for large volume Petroleum based Organic

Chemicals Manufacturing, Petroleum-based Polymers

Manufacturing, Thermal Power, Crude Oil Petroleum

Product Terminals, Ports & Harbors and Water &

Sanitation

Reference: Section 2.2.5 for OECD Guidelines and Section

2.2.2 for IFC Guidelines


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No. Section/ Page


1.2 ESIA for all associated facilities should be conducted in the

same manner as the primary facility and borrower has to be

establish the relevant management plans and mitigation

measures for their risks and impacts

The ESIA study covers the different components of the

proposed project namely; Ethylene Plant (P1), Polyethylene

Plant (P2) and Utilities &Offsite (including but not limited to:

seawater intake and outfall, power generation units, desalination

plant and storage tanks.

A full list of the different components covered by the ESIA study

is presented in Table 3-2 of the ESIA Report.

Separate mitigation measures and management commitments

for the individual components were provided as necessary and

applicable in the ESIA study.

1.3 According to Annex I of the common Approaches, the

proposed project is classified as Category A considering the

Sixth example of Annex I

Noted. A clear statement on the proposed complex classification

has been added to the ESIA Report.

Reference: Section 2.2.5

IFC PS1 assessment and management of

environmental and social risks and impacts

1.4 The ESMS (Environmental and Social Management System)

has not yet made available to review. So the ESMS has to be

developed

Noted. A separate section for an ESMS framework is presented

in the ESIA report outlining the main elements of an ESMS (e.g.

policy and management programs, etc.).

Reference: Section 8

1.5 The construction Environmental and Social Management Plans

(CESMP) should be further refined to ensure alignment with

IFC EHS Guideline.

The scope of the ESIA is limited to presenting a framework for

the CESMP. The framework was reviewed and refined, as

needed, to ensure alignment with IFC Guidelines.

Reference: Section 9.2


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No. Section/ Page


1.6 Identify the range of stakeholder engagement plan that is

scaled to the project risks, impacts and development stage. The stakeholders defined for this project included project

affected people such as individuals and families living near the

project, the project sponsor; public sector representatives such

as local elected officials and local and central government

departments; organizations such as local, national non-

governmental organizations (NGOs), universities and research

centers and other private sector companies and business

associations. Stakeholders were classified as:

Primary stakeholders: individuals, groups or local

communities that may be affected by the project, and

Secondary stakeholders: broader stakeholders who may

be able to influence the outcome of the project because of

their knowledge about the affected communities or

political influence over them.

Both categories were efficiently engaged through socio-

economic survey and two public hearings. More details on the

stakeholders’ engagement methodology as well as main findings

of the socio-economic survey and the public hearing sessions

are presented in the ESIA. A description of the stakeholder

engagement during the study shall be also added to the

executive summary of the ESIA.



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No. Section/ Page


IFC PS2 Labor and Working Condition

1.7 ESIA has to establish appropriate human resources policies

and procedures to meet the requirement of host country

Establishing human resources policies is not part of the ESIA

scope. However, it is worth mentioning that Carbon Holding

(main investor and operator of Tahrir Petrochemicals) has

Corporate Governance & Policies that are applicable to the

project.

Furthermore, Tahrir Petrochemicals is committed to comply with

the host country (i.e. Egypt) Labour Law and

international/regional conventions presented in the ESIA Report.

Reference: Section 2.1.2: SOCIAL AND LABOUR

REGULATORY CONSIDERATIONS and Section 2.3.

1.8 Provide workers with accommodation for all basic needs Noted. Similar statement has been incorporated in the ESIA

where appropriate.


1.9 Cite Borrower Policy statement/guideline/management/ Policy

procedure where use of Child/force labor has been explicitly

prohibited

Tahrir Petrochemicals is committed to comply with the Egyptian

Labour Law, presented in the ESIA Report.

Additionally, Tahrir Petrochemicals is committed to comply with

the different international conventions signed by the Egyptian

Governorate that prohibits Child/Forced labour (e.g. Convention

concerning the Prohibition and Immediate Action for the

Elimination of the Worst Forms of Child Labour).

Reference: Section 2.1.2: SOCIAL AND LABOUR

REGULATORY CONSIDERATIONS and Section 2.3.


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No. Section/ Page


1.10 Provide audit records/communications from

suppliers/contractors ensuring Child/Forced labor is prohibited

in their respective business

In general, Tahrir Petrochemicals is committed that all

suppliers/contractors involved in the proposed project shall

comply with the Egyptian Labour Law.

It is worth mentioning that official audits will be conducted via

regional labor governmental officials in Suez through random

checks/audits.

1.11 Establish the worker Health and Safety Plan and it should

addressed in the ESIA

Developing Occupational Health and Safety Plan (OHSP) is not

part of the scope of the present ESIA; however, Tahrir

Petrochemicals shall develop a detailed OHSP at a later stage

of the project, namely detailed engineering.

1.12 Collective bargaining, fair salaries in line with the industry,

reasonable work hours should be addressed including

contracts for all in the ESIA


Labour Law presented in the ESIA Report.


1.13 It should be clear that all workers (including those working

through contractors) will have a written contract. Please refer to Response to Comment No: 1.10.

1.14 Provide details on the following EHS Guideline elements with

respect to general facility design and operation (Section 2.1 of

IFC General EHS Guideline).

Integrity of Workplace Structure/Severe weather and Facility

shutdown/Workspace and exit/Fire precautions/ Lavatories

and Showers/ Potable water Supply/ Clean eating area/

Lighting/ Safe Access / First aid Air Supply/ Work environment

temperature

EHS Guidelines are integrated in the ESIA study as applicable.



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No. Section/ Page


1.15 Explain how following elements meet the EHS Guideline about

Physical hazard. (Section 2.3. of IFC General EHS Guideline).

o Rotating and Moving equipment / Noise (refer to

Appendix B, Table 16), Vibration/Electrical (refer to

Appendix B, Table 2 which illustrates GIIP for no

approach zone for high voltage power line)

o Eye hazards/ Welding / Hot work / Industrial vehicle

driving and site traffic

o Working environment temperature / Ergonomics

respective motions, manual handing.

Please refer to Schedule 24: Project Execution Plan and

Schedule 23: Basis of Design.

1.16 The risks and impacts identification process will also consider

those risks and impacts associated with primary supply chains.

No information has been provided at this stages as to how

primary supply chain risks are mitigated apart from

contractors. So borrower has to address supply chain issues

through ESMS.

Please refer to Response to Comment No: 1.4.


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No. Section/ Page


IFC PS3 resource Efficiency and Pollution Prevention

1.17 Greenhouse Gas (GHG) emissions need to be quantified using

an internationally accepted methodology and provide an

alternative analysis to reduce project related GHGs during the

design and operation of the project as per the requirements of

this IFC performance standard.

Noted, GHG is quantified as far as practical during the proposed

project operation phase using the following reference document:

“European Investment Bank Induced GHG Footprint-The carbon

footprint of projects financed by the Bank-Methodologies for the

Assessment of Project GHG Emissions and Emission

Variations, Version 10.1”

Greenhouse gases reduction measures are presented in the

ESIA.

Reference: Section 6.3.1: Global Climate and Section 7.2.1:

Global Climate

1.18 The approach to reducing GHG emissions, energy efficiency

strategy, and GHG estimation methodology needs to be

provided in the ESIA.

Please refer to Item 1.17.


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No. Section/ Page


1.19 Describe whether wastewater management plan considers the

following aspects in accordance with the EHS Guideline

(Section 1.3. of IFC General EHS Guideline) or any specific

industry guideline standards

o Industrial wastewater (process wastewater,

utilities operation wastewater and storm

water etc.)

o Sanitary wastewater (in the absence of

relevant national/local standards. Appendix B

table 13 should be referred)

o Residuals from wastewater treatment

operations

o Occupational health and safety issues in

wastewater treatment operations

o Monitoring of the management plan

In general, the wastewater management of the proposed

complex is following the EHS Guidelines.

Details on the industrial and sanitary wastewater treatment

systems are presented in Section 3.7.7.

Residuals from wastewater treatment operations management is

presented in Section 3.7.7 and Section 3.8.2.

Occupational health and safety is not part of the proposed ESIA

scope. Nonetheless, Tahrir Petrochemicals shall develop a

detailed OHSP at a later stage of the project, namely detailed

engineering.

Monitoring requirements for treated wastewater are presented in

Section 9.3.4.

1.20 formulate and implement an integrated pest use and

management plan The formulation of pest use and management plan is not part of

the ESIA scope.

IFC PS4 Community Health, Safety and Security

1.21 Identify and establish sufficient mitigation or control measures

to avoid or minimize transmission of communicate disease

that may be associated with the influx of project related

workers


Labour Law presented in Section 2.1.2 of the ESIA Report. The

Labour Law specifies the appropriate procedures and measures

for maintaining the well-being of workers.

Additionally, Tahrir Petrochemicals is committed to conduct

medical checks for the proposed project personnel before

joining the project in additional to regular medical checks.


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No. Section/ Page


1.22 Establish a security management plan and provide sufficient

training to the security personal; it has to provide a grievance

mechanism for affected communities to express concerns

regarding the security arrangement.

Site Security Framework developed for the proposed Complex

and presented in Appendix 9.

A grievance mechanism framework is presented in the ESIA

Report.


1.23 IFC PS8 Cultural heritage

One archaeological site is located at a distance of

approximately 13km far from the project area. So ESIA has to

develop provisions for managing a project-specific procedure

that outlines the actions to be taken if previously unknown

cultural heritage is encountered

The proposed project main plant area is located at a designated

industrial zone, namely Economic Zone. Similarly, the port

facilities are located at an existing and operating port, namely

Sokhna-1 (McDermott) Port.

Consequently it is unlikely to encounter any cultural heritage

sites at the project area.

However, the procedures that outline the necessary actions to

be taken in similar situations are included in the ESIA Report.

Reference: Table 9-2-Item 6


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No. Section/ Page


1.24 More details required on an earthquake contingency

plan and mitigation measures and also need to make

EPC develop the seismic design

The ESIA scope does not include an earthquake contingency

plan.

However, the relevant information regarding the seismic activity

at the proposed project area has been presented in the ESIA

study in Section 4.3.2: Seismic Conditions.

It is worth noting that the gathered information indicates low

seismic activity at the study area “The instruments of Helwan

station and International Seismic Network in Ain Sokhna have

not recorded any earthquakes exceeding 4.0 on the Richter

scale. It is worth mentioning that an earthquake of magnitude 6

to 7 is usually classified as a moderate earthquake”.

Furthermore, referring to Project BOD Clause 2.3.2 titled

General Seismic Requirements which Stipulated that, all

Structures and Equipment other than flat bottomed, vertically

oriented storage tanks shall be designed to resist earthquake

forces in accordance with ASCE 7-05 ―”Minimum Design

Loads for Buildings & Other Structures”.

And Clause 2.3.3 titled Seismic Requirements for Storage Tanks

which Stipulated that Earthquake Load for Storage Tanks shall

be in accordance with API 620, API 625, API 650 or API 2510.

API 625 will be followed for Cryogenic Double Wall Storage

Tank.


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No. Section/ Page


1.25 The FRA (Flood Risk Assessment) should be 100 year and

incorporate protection measures for area north of the

site/Cairo Sokhna old road. So it has to establish a flood

contingency plan on a 1 to 100 year return period flood.

Relevant information is presented in the ESIA study.


It is worth noting that Tahrir Petrochemicals is talking to the

government bodies responsible for flood management and the

Government is working on launching a regional study for

Sokhna region flood protection and risk mitigation.

1.26 Provide external (independent) monitoring plan including

duration, Frequency, responsible parties of the monitoring for

the operation phase. Revisit the operational monitoring to

include the online monitoring also the durations and

frequencies for some parameters were not clearly defined

The ESIA scope is limited to presenting a framework for the

Environmental and Social Management Plan that includes the

monitoring requirements.

However, relevant information as appropriate are presented in

the ESIA Report (e.g. continuous monitoring).


2.1 p. 23 paragraph above Table 2-11 references Table 2-12, but should be 2-11

Noted and updated in the ESIA Report.

2.2 p. 27 Section on Crude Oil and Petroleum Product Terminals and VOC emissions is not clear. The Guideline should be briefly

summarized here to make this section consistent with others.


Reference: Section 2.2.2- CRUDE OIL AND PETROLEUM PRODUCT TERMINALS

2.3 p.45 Table 3-4; information for ethane/ethylene pipeline diameter is blank

Noted and updated in the ESIA Report as per Tahrir Petrochemicals provided information.

Reference: Table 3-4

2.4 p.55 footnote at bottom of Table 3-5 references 140 KTA of

propylene sent to “local consumers”. Should align with other documents that show either 160, 180 or 185 KTA (OPC

capacity)




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No. Section/ Page


2.5 p.56 under the naphtha paragraph, reference is made to 4,000

kg/hr. Should be tonne/hr. Noted and updated in the ESIA Report.

Reference: Section 3.6.3: Naphtha

2.6 p.57 paragraph under “Energy” should be revised to be consistent with current plans – ca 20 MMSCFD of natural gas


Reference: Section 3.6.3: Power

2.7 p.67 –

3.7.6

Fuel Gas System - should be revised to be consistent with

current plans – ca 20 MMSCFD of natural gas Noted and updated in the Report as per Tahrir Petrochemicals provided information

Reference: Section 3.7.6: Fuel Gas System

2.8 p 74-80/ Table 3-

22

List of Solid Wastes During Operating Phase. Probably need to add tank cleaning wastes (primarily naphtha, PGO, PFO)

Noted and added to Section 3.8.2: Solid Wastes-Operation Phase in the ESIA Report as per Tahrir Petrochemicals provided information.

2.9 p82 – Table 3-

24

Air Emissions Sources Characteristics – table does not show boilers and should be updated to be aligned with current plans

and fuel sources.

The Table has been updated to include all the potential continuous air emissions sources during operation phase and aligned with Tahrir Petrochemicals plans and fuel resources.



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No. Section/ Page


2.10 p88 Site-Specific Air Quality Measurements – is two days adequate

to develop a baseline?

The air quality baseline is not assessed by the site specific measurements only; it is also assessed based on measurements presented in Table 4-1 and Figures 4-1 to Figure 4-3.

Some of the information in this section presents the results of a sampling period that extends from 2000 to 2008 and thus adequate to develop a baseline.

Furthermore, WorleyParsons conducted another air monitoring campaign in the vicinity of the port area and added more historical measurements for air quality in the area that covered the period from 2009 to 2013. The results and analysis of these measurements are presented as part of the ESIA Report.

Reference: Section4.1.1: HISTORICAL AMBIENT AIR QUALITY MEASUREMENTS

And Section 4.1.1: SITE-SPECIFIC AIR QUALITY MEASUREMENTS


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No. Section/ Page


2.11 Table 6-

2

Air (first row) characterized as “Medium” instead of “High”?

Not clear why population (which is low in area) is scored as

“High”; Not clear why economic activities categorized as “High”

Air: The air quality within the proposed Complex area affects the local community well-being and health and thus can be classified as a Medium VR: “VR containing local designations and/or features of local public value”. The effect of the proposed Complex on the ambient air quality is generally localized.

Population: The table presents the value/importance of the receptor regardless its magnitude. It is believed that the value of population (life, well-being, etc) is high. Furthermore, the low density of population in the area is reflected in the magnitude that has been classified as “low: A small proportion of the VR is affected” and “Very Low: A very small proportion of the VR is affected”

Economic activities: Egypt is classified as a low income country. Thus it is believed that economic activities which provide livelihood for population have a High importance to the local community.

2.12 Table 6-

3

Should consider adding “flaring and releases” to the

“Accidental Events” category at bottom. Noted and to be updated in the ESIA Report.


2.13 Section 6.2

Predicted Impacts During Construction Phase – may need to note that the dredging operation will impact land/soil (storage

of dredging material) and that there are environmental considerations for storage. Should also address dewatering

plans. See for example:

http://water.epa.gov/type/oceb/oceandumping/dredgedmaterial/evaluation.cfm Dredging impacts to marine/biodiversity are

discussed (p.200) but not impacts resulting from dredge material removed (6 million m3). Also consider impacts to

population from foul odors.


Reference: Section 6.2.2 and Section 6.2.5


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No. Section/ Page


2.14 Table 6-

6 (p.

203-206)

consider adding “Dredging Activities” as an Aspect Noted and updated in the ESIA Report.

Reference: Table 6-3 and Table 6-6

2.15 6.3 Predicted Impacts during Operation Phase – entire section requires updating (including tables 6-7, 6-8, 6-9) due to

addition of four boilers and low-quality liquid fuel combustion.

Biggest impacts are likely to be NO2 and SO2


Reference: Section 6.3.1, Section 6.3.5, Table 6-7, Table 6-8 and Table 6-9

2.16 p. 207 first paragraph. Although the testing and start-up duration is

expected to be less than one year, it is during this time that

heavy flaring and the increased risk of vapor and liquid releases will be highest. It is not obvious that this period

should be classified as “very low”

The “Very Low” reflects the duration of the testing and start-up activities which is expected to be less than one year.

As for the heavy flaring and the increased risk of different releases, they are reflected in the magnitude of the impact which has been classified as “Very High” or “High” or “Moderate” depending on the VR and event.

2.17 Table 6-10 pp

220-222

Should “Major Maintenance Turnaround” be added as an “Aspect”, given the large influx of workers, related traffic,

stoppage and restart of the plant, etc?

There is no need to include “Major Maintenance Turnaround” as a separate aspect as all the relevant impacts are already covered as part of Plant equipment testing and start-up stage (commissioning).

2.18 As noted previously, consider adding “Dredging Activities” as

an “Aspect” to mitigation measures during construction (Table 7-1).


Reference: Table 7-1, Section 7.1.2 and Section 7.1.3.

2.19 p.243 Mitigation measures during operation phase – Air. Bullet 6 – consider extending to include reporting as part of the leak

detection and management process


Reference: Section 7.2.1”Bullet 11”

2.20 p.243 Mitigation measures during operation phase – Air. Last bullet references “Best Available Technologies” for emissions

reduction. This should probably be further elaborated, and

examples provided, such as the use of low-NOx burners, use of selective catalytic reduction (SCR) methods for NOx

minimization, for furnaces above a certain threshold size, etc.

Noted and updated in the ESIA Report after consultation with Tahrir Petrochemicals.

Reference: Section 7.2.1. ”Bullet number 16”.


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2.21 p.243 Mitigation measures during operation phase – Air. Consider

adding a comment about monitoring of naphtha sulphur

content for SO2 emissions considerations (liquid boiler fuels).


Reference: Section 7.2.1”Bullet number 14”.

2.22 p.245 under Seawater. Consider adding temperature measurement/alarming/reporting for all outfall streams


Reference: Section 7.2.3-Seawater”Bullet number 3”.

2.23 p.252/ Sec

7.3

Mitigation Measures during Non-Routine Events throughout the Project Phases. The list of bullets about management and

control measures should be expanded to include preventative

concepts such as proper definition and documentation of standard procedures, work permitting rules and procedures,

safety training and safety aspects integrated into all operating/maintenance procedures, effective management of

change (MOC) processes and the like. Also, HAZOP reviews

and similar during detailed design.

Noted and updated in the ESIA Report as applicable.

Reference: Section 7.3”Bullet number 8”.

2.24 Sec 8 Not sure where it might best apply, but should a requirement

for plant personnel air monitoring badges be included? Maybe under Air Quality (Table 8-3) and Table 8-4 Operations

Environmental Monitoring and Auditing Plan. See examples

from links below: http://www.grainger.com/content/qt-safety-air-monitoring-

equipment-231 http://multimedia.3m.com/mws/media/211130O/air-

monitoring-guide-3500-3510-3520-3530-3550-3551.pdf

This item is relevant to Occupational Health and Safety and thus out of the ESIA scope. However Tahrir Petrochemicals is committed to develop a detailed OHSP at the detailed design phase of the project.

2.25.a Appendix 3 – Air

Dispersion

Model

Needs to be updated and aligned with current fuels configuration, including four boilers


Reference: Appendix 3- Table 4-1


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No. Section/ Page


2.25.b Appendi

x 3 – Air

Dispersion

Model /p.2 –

Scenario B.

Furnace decoking frequency will be six times per year each

furnace so almost 50 times per year in total (not six). This

needs to be better reflected in the verbiage and the AERMOD inputs.

Noted and to updated in the ESIA Report, as applicable.

Reference: Appendix 3

2.26 Appendi

x 3 – Air Dispersi

on

Model

General comment: are there any diesel fire water pumps or

other liquid-fuel driven generators, pumps, etc.? If so, these should be included (although not material) if expected to be in

operation

All the possible continuous air emissions sources are incorporated in the air dispersion model.

Modelling discontinuous sources such as fire water pumps and generators is out of the scope of the air dispersion model.

2.27 Appendix 3 – Air

Dispersi

on Model/

p.4 – Table 2-

1

For clarity, shouldn’t the “WHO” label in the fourth column be replaced by IFC, as noted in the text in second-to-last

paragraph of p.2?

Noted and updated in the air dispersion model Report.

Reference: Appendix 3- Table 2-1

2.28 Appendix 3 – Air

Dispersion

Model/

p.6

p.6 – Comments about PM10 As noted previously, given the short duration of ambient air testing (two days) and the

relatively high PM10 (non-compliant with EU), won’t additional data be required? Also, related to this, does the EU Directive

come into play? Do not IFC standards govern (as noted

previously)?

Tahrir Petrochemicals is considering the national limits, IFC guidelines in addition to the EU guidelines to show its compliance and commitment towards environmental preservation.

The additional ambient air quality measurements and analysis are presented as part of Section 4- Description of Receiving Environment (Please refer to Comment No: 2.10).


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2.29 General Cumulative impacts assessment: ESIA should address the

cumulative impacts through consideration of the impacts of

the Project and other future projects taking place in the vicinity which could affect the same social and environmental

resources and receptors that can be expected to have a combined effect. The impact of existing permitted facilities

operating in the region is reflected in the baseline environmental quality: therefore, cumulative impacts have

been assessed considering the impacts from the proposed

development in combination with other future planned projects in the area.

WorleyParsons followed EEAA definition of “Cumulative impact” as stated in the Guidelines of Principles and Procedures for Environmental Impact Assessment, Second edition.

The definition of Cumulative Impact is “The aggregate of individual impacts of the activities of the project or the individual impacts of the project to those of other surrounding projects or activities.” (Section 6.4.2.6 Assessment of Impacts- Category C Projects).

No reference is made to including the future/planned establishments and facilities as part of the environmental impact assessment in the EEAA Guidelines.

A clear statement of the definition of the cumulative impact has been added to the ESIA Report

Reference: Section 6.1.4.

2.30 General Greenhouse Gas (GHG) Emission: ESIA should include the

projected amount of GHG annual emission during each phase calculated by the internationally recognized methodology as

well as monitoring the method on quantification of GHG emission.

Please refer to Item 1.17.

2.31 General Assessment for Waste Management Plan: There isn’t the

dedicated assessment for waste management plan in ESIA, which should address the existing waste management facilities

that are available for Project and evaluate the potential impacts resulting from waste management during the lifetime

of Project.

Noted. Available details on the waste management facilities in Suez governorate will be added to Section 4- Description of the Receiving Environment in the ESIA Report.

The potential impact resulting from waste during the different phases of the project is already incorporated in Section 6- Environmental and Social Impact Assessment.


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2.32 General Assessment for Health aspects: The assessment should be

included in ESIA to provide information on regional health

infrastructure, the baseline health data for the region where the Project is located. If there is any material adverse impact

to environment, social bracket and infrastructure, the viable mitigation measure should be recommended.

The scope of the present study is limited to evaluating the environmental and social impacts. However, details on the health baseline and infrastructure for Suez as applicable have been added to the ESIA Report.


2.33 General Emergency response plan (ERP): ERP should be prepared to

prevent injury to staff and personnel, damage to property, harm to the environment and impact on neighbor

communities. One of the major significant negative impacts for Project is due to impacts to recreational resorts in

particular. The viable ERP which addresses procedures not to

harm them should be in place.

Noted. WorleyParsons incorporated Tahrir Petrochemicals ERP framework as applicable as part of the ESIA Report.

Reference: Appendix 9

2.34 General Environmental and social management plan (ESMP): ESMPs for each development phase have been also incorporated in

ESIA, however, they are too general to address the mitigation,

monitoring and institutional measures to be taken by Project to eliminate adverse E&S impacts. It appears that the

mitigation measures resulting from the impact assessment are not appropriately reflected on ESMP.



2.35 General Grievance Mechanism and Stakeholder Engagement Plan

(SEP): Section 9, Public consultation and stakeholder engagement, provides the identification of stakeholders for

Project and discussion of 1st public hearing. However, Stakeholder Engagement is ongoing process to be developed

and implemented along with the development stage of

Project. The specific plan should be established in accordance with IFC PS1. Together with this, Sponsors should establish a

grievance mechanism to receive and facilitate resolution of affected communities’ concerns and grievances about Project’s

E&S performance

Noted. The results of the second public hearing have been added to the ESIA Report in addition to a framework for

Grievance Mechanism.

Reference: Section 10.4 and Section 10.5.


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E.1 General The use of IFC’s Ports & Harbors Guidelines especially for

dredging operations, dredging impacts on marine ecosystems, disposal of dredged material, etc.



E.2 General Comparing project’s emissions/discharges to IFC’s EHS

Guidelines (Large Volume Petroleum-Based Organic

Chemicals, Petroleum-Based Polymers, Thermal Power, General, etc.); management of wastewaters, clarifying if any

unlined ponds will be used or not; treated water recycling; the use of treated effluents in irrigation and applicable Guidelines,

etc.; demonstrating compliance with these Guidelines and

adopting mitigation measures, if needed; hazardous waste management especially what can go to landfill and what

should not, etc.; hazardous waste treatment and disposal options, etc.

Some of these items are already addressed in the Draft ESIA

Report (e.g. the use of treated effluents in irrigation and

applicable Guidelines, hazardous waste management especially

what can go to landfill and what should not, etc.; hazardous

waste treatment and disposal options, etc.).

For the rest of the presented points, noted and updated in the

ESIA Report.

Reference: Section 3.7.7,Section 3.8, Table 3-25, Table 6-7, Table 6-9, Figure 6-2, Figure 6-3, Figure 6-5 and Figure 7-1.

E.3 General Emergency response measures for process upsets, levels to be

used for exposure assessment, etc. Please refer to item 2.33 and Appendix 8 (QRA study).

E.4 General Environmental management and monitoring framework/plans

etc.(right now, it’s premature to go into too many details but

we can present a framework that is a little more detailed than the one presented in the EIA).


Reference: Section 9.2.3 and Section 9.3.4.

E.5 General Identifying any vulnerable people in the project’s area of influence such as any indigenous people/Bedouins, etc.; how

the project is addressing comments from stakeholders, etc.

Noted and updated in the ESIA Report, as applicable.

Reference: Section 10.5.

E.6 General Occupational health, sand safety; environmental and social

management system; community safety; land acquisition; cultural property; and any other issues associated with the

compliance with IFC’s Performance Standards.

Noted and updated in the ESIA Report, as applicable to the project and study scope.



Page 21 of 21

No. Section/ Page


Additional Notes (if any)

No.1.x: Second set of comments received on 26.11.2014

No.2.x: First set of comments received on 13.11.2014

No. E.x: Comments received by email on 12.10.2014

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Comment Response Sheet Response Remarks ... engineering. Monitoring requirements for treated wastewater are presented in ... Comment Response Sheet